Download or read book Limitation on Benefits Clauses in Double Taxation Conventions written by Félix Alberto Vega Borrego and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 438 pages. Available in PDF, EPUB and Kindle. Book excerpt: Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.

Download or read book Guide to Foreign and International Legal Citations written by and published by . This book was released on 2006 with total page 300 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Formerly known as the International Citation Manual"--p. xv.

Download or read book Bulletin for International Fiscal Documentation written by and published by . This book was released on 2005 with total page 580 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book The Attribution of Profits to Permanent Establishments written by Raffaele Russo and published by IBFD. This book was released on 2005 with total page 488 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The attribution of profits to permanent establishments (PEs) is probably one of the most complex subjects of the international tax arena. The interaction of treaty rules and domestic legislations sometimes leads to unacceptable results such as double taxation or double non-taxation. This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries."--Extracted from publisher website on June 29, 2016

Download or read book Guide to Community Customs Legislation written by Michael Lux and published by Emile Bruylant. This book was released on 2002 with total page 621 pages. Available in PDF, EPUB and Kindle. Book excerpt: The customs union is an essential element of the European Community's single market with its four basic freedoms: free circulation of goods, persons, services and capital. This single market with currently 370 million consumers is the largest in the industrialised world. The single market with no internal barriers and common rules for trade with the outside world is the catalyst for economic integration within the Community as well as for the liberalisation and promotion of world trade. Customs policy and legislation are one of the cornerstones of the single market, as well as the Community's trade, development and agricultural policy. They are furthermore linked to the collection of VAT and excise duties at importation and the relief from such taxes at exportation. Globalisation of international trade, e-commerce and the forthcoming enlargement of the Community increase the need for information on customs rules. This book contains 19 well-structured chapters with summaries, illustrative examples, law tables, rulings of the European Courts, case studies, as well as a glossary of customs terms so that it can be used both as a study tool and as a reference book for all aspects of customs legislation. It is an indispensable and reliable tool for all who require clear, comprehensive and up to date information in this field, and includes a wealth of detail for all those involved in international trade issues, such as importers and exporters, customs agents, customs officials, lawyers, consultants and trade federations.

Download or read book Tax Systems written by Joel Slemrod and published by MIT Press. This book was released on 2013-12-13 with total page 235 pages. Available in PDF, EPUB and Kindle. Book excerpt: An approach to taxation that goes beyond an emphasis on tax rates to consider such aspects as administration, compliance, and remittance. Despite its theoretical elegance, the standard optimal tax model has significant limitations. In this book, Joel Slemrod and Christian Gillitzer argue that tax analysis must move beyond the emphasis on optimal tax rates and bases to consider such aspects of taxation as administration, compliance, and remittance. Slemrod and Gillitzer explore what they term a tax-systems approach, which takes tax evasion seriously; revisits the issue of remittance, or who writes the check to cover tax liability (employer or employee, retailer or consumer); incorporates administrative and compliance costs; recognizes a range of behavioral responses to tax rates; considers nonstandard instruments, including tax base breadth and enforcement effort; and acknowledges that tighter enforcement is sometimes a more socially desirable way to raise revenue than an increase in statutory tax rates. Policy makers, Slemrod and Gillitzer argue, would be well advised to recognize the interrelationship of tax rates, bases, enforcement, and administration, and acknowledge that tax policy is really tax-systems policy.

Download or read book Customs Modernization Handbook written by Luc De Wulf and published by World Bank Publications. This book was released on 2005-01-03 with total page 356 pages. Available in PDF, EPUB and Kindle. Book excerpt: Trade integration contributes substantially to economic development and poverty alleviation. In recent years much progress was made to liberalize the trade regime, but customs procedures are often still complex, costly and non-transparent. This situation leads to misallocation of resources. 'Customs Modernization Handbook' provides an overview of the key elements of a successful customs modernization strategy and draws lessons from a number of successful customs reforms as well as from customs reform projects that have been undertaken by the World Bank. It describes a number of key import procedures, that have proved particularly troublesome for customs administrations and traders, and provides practical guidelines to enhance their efficiency. The Handbook also reviews the appropriate legal framework for customs operations as well as strategies to combat corruption.

Download or read book Global Investment Competitiveness Report 2017 2018 written by World Bank Group and published by World Bank Publications. This book was released on 2017-10-25 with total page 281 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Global Investment Competitiveness report presents new insights and evidence on drivers of foreign direct investment (FDI) in developing countries, and FDI’s role in development. The report’s survey of 750 executives of multinational corporations finds that a business-friendly legal and regulatory environment is a key driver of investment decisions in developing countries, along with political stability, security, and macroeconomic conditions. The report’s topic-specific chapters explore the potential of FDI to create new growth opportunities for local firms, assess the power of tax holidays and other fiscal incentives to attract FDI, analyze characteristics of FDI originating in developing countries, and examine the experience of foreign investors in countries affected by conflict and fragility. Three key features of this Global Investment Competitiveness report distinguish it from other publications on FDI. First, its insights are based on a combination of first-hand perspectives of investors, extensive analysis of available data and evidence, and international good practices in investment policy design and implementation. Secondly, rather than exploring broad FDI trends, the report provides detailed and unique analysis of FDI depending on its motivation, sector, geographic origin and destination, and phase of investment. Thirdly, the report offers practical and actionable recommendations to policymakers in developing countries wishing to reform their business climates for increased investment competitiveness. As such, the report is meant to complement other knowledge products of the World Bank Group focused even more explicitly on country-level data, detailed reform diagnostics, and presentation of best practices. We are confident this report will bring value and fresh perspectives to a variety of audiences. To governments and policymakers, including investment promotion professionals, the report offers direct insights into the role of government policies and actions in investors’ decision-making. To foreign investors and site location consultants, the report provides information on FDI trends and drivers across sectors and geographies. For academic audiences, the new datasets on investment incentives and FDI motivations enables opportunities for additional research and analysis. Lastly, for development assistance providers and other stakeholders, the report highlights key approaches for maximizing FDI’s benefits for development.

Download or read book The Rational Spirit in Modern Continuum Mechanics written by Chi-Sing Man and published by Springer. This book was released on 2004-07-06 with total page 918 pages. Available in PDF, EPUB and Kindle. Book excerpt: Through his voluminous and in?uential writings, editorial activities, organi- tional leadership, intellectual acumen, and strong sense of history, Clifford - brose Truesdell III (1919–2000) was the main architect for the renaissance of - tional continuum mechanics since the middle of the twentieth century. The present collection of 42 essays and research papers pays tribute to this man of mathematics, science, and natural philosophy as well as to his legacy. The ?rst ?ve essays by B. D. Coleman, E. Giusti, W. Noll, J. Serrin, and D. Speiser were texts of addresses given by their authors at the Meeting in memory of Clifford Truesdell, which was held in Pisa in November 2000. In these essays the reader will ?nd personal reminiscences of Clifford Truesdell the man and of some of his activities as scientist, author, editor, historian of exact sciences, and principal founding member of the Society for Natural Philosophy. The bulk of the collection comprises 37 research papers which bear witness to the Truesdellian legacy. These papers cover a wide range of topics; what ties them together is the rational spirit. Clifford Truesdell, in his address upon receipt of a Birkhoff Prize in 1978, put the essence of modern continuum mechanics succinctly as “conceptual analysis, analysis not in the sense of the technical term but in the root meaning: logical criticism, dissection, and creative scrutiny.

Download or read book Tax Reform in Developing Countries written by Wayne R. Thirsk and published by World Bank Publications. This book was released on 1997 with total page 436 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax Reform in Developing Countries carefully examines the experience of eight developing countries that have undergone -- and in some instances are still undergoing -- significant and comprehensive tax reform. The countries are Bolivia, Colombia, Indonesia, Jamaica, Korea, Mexico, Morocco, and Turkey. It draws on their experiences to find lessons learned and to see how they may be applied to other countries on the road to tax reform. Equal attention is given to the process of tax reform, how it is implemented, and the substance or results of reform efforts. Throughout, the focus is on the practical rather than the theoretical aspects of tax reform.

Download or read book Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle written by Eva Escribano and published by Kluwer Law International B.V.. This book was released on 2019-05-10 with total page 254 pages. Available in PDF, EPUB and Kindle. Book excerpt: Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.

Download or read book The North American Mosaic written by Commission for Environmental Cooperation (Montréal, Québec). Secretariat and published by . This book was released on 2001 with total page 240 pages. Available in PDF, EPUB and Kindle. Book excerpt: The North American Mosaic has four overarching features. First, it is, to the extent feasible, based on comparable information on the status and trends of major indicators of the state of the environment in Canada,Mexico, and the United States. Second, the report confirms that these three countries together make up an incredibly complex, dynamic, and interconnected ecosystem in which humans play a dominant and decisive role. Third, the report raises important and sometimes disquieting questions concerning the sustainability of some current trends. Finally, the report is a reminder that our economic, social, and physical well-being are utterly dependent on the life-sustaining services provided by nature. This report emphasizes the importance of developing mutually compatible economic, social, and environmental goals and policies across the three-country region.

Download or read book The EU and Third Countries written by Michael Lang and published by Kluwer Law International. This book was released on 2007 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis by tax scholars on the relations between European law and third countries in the field of direct taxation. It includes national reports from over 30 EU Member States and third countries, which were presented at a conference held at the Vienna University of Economics and Business Administration on 13-15 October 2006. Among the areas addressed by this work are the following: The direct impact of article 56 EC Treaty (right of establishment) in the relations with third states; The indirect impact of the fundamental freedoms in the relations with third states; Fundamental freedoms in relation to EEA States under the EEA Agreement; Agreements between Switzerland and the European Union; The relations with other third states in the field of direct taxes; The impact of secondary EC law on the relations with third states; Article 307 EC Treaty (free movement of capital); and The treaty-making power of the European Union in the relations with third states.

Download or read book Host Bibliographic Record for Boundwith Item Barcode 30112044669122 and Others written by and published by . This book was released on 2013 with total page 2130 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Transactional Adjustments in Transfer Pricing written by Aitor Navarro and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Entrepreneurship Policy Theory and Practice written by Anders Lundstrom and published by Springer Science & Business Media. This book was released on 2005-09-21 with total page 316 pages. Available in PDF, EPUB and Kindle. Book excerpt: Entrepreneurship Policy: Theory and Practice is the first book to fully analyze the construction of entrepreneurship policy, a rapidly-evolving area of policy about which little is known. From a study and assessment of the practices of governments in thirteen countries in Europe, North America and the Asia-Pacific, this book fully describes the policy area and shares new tools and methods for better understanding and explaining the why and how of an entrepreneurship policy approach. Unlike other research in the field of entrepreneurship where implications from research findings are used to suggest what policy actions should be taken to increase the level of entrepreneurship in an economy, this study is based on what entrepreneurship policy actions are being taken. This is a unique book in the field which points to the way forward both for policymakers and for the research community in terms of thinking about entrepreneurship policy and the complex issues surrounding its development.

Download or read book Taxation and Migration written by Reuven S. Avi-Yonah and published by Kluwer Law International B.V.. This book was released on 2015-08-21 with total page 224 pages. Available in PDF, EPUB and Kindle. Book excerpt: Migration has become an increasingly important phenomenon for societies, especially given its highly controversial political dimension. The complexity of the migrant integration process and its many varieties present challenges to policymakers who need high-quality information on which to base decisions. Nowhere is this necessity more pressing than in the development of relevant tax rules that meet the basic requirements of efficiency and equity. Moreover, the ascent of the so-called emerging economies coupled with the stagnation of the richest economies of the world implies reform of the current competition-based international tax regime and the adoption of a more cooperative paradigm. This important and timely book, for the first time in such depth, explores such aspects of the problem as the following: - migration for tax reasons, especially corporate "inversions" (change in corporate residence for tax purposes); - tax consequences related to individuals who receive free or subsidized education in one country and profit from it in another; - taxing cross-border retirement income; and - migration-related aspects of tax preferential treatment of the elderly. With particular emphasis on the effects and opportunities created by the changing international tax regime - and with attention to the role of tax treaties and recent court cases - chapters by well known tax experts present evidence on the consequences of migration in all its facets and simulate the effects of several recently enacted and proposed changes in tax law in European countries, the United States, and other jurisdictions. The grounded propositions and recommendations offered in this deeply informed book will allow policymakers to draft tax-residence rules that minimize distortion and promote fairness. The book will also be of interest to tax law practitioners and other tax specialists, migration experts, and academics investigating one of the crucial political issues of our time.